排污权交易制度是环境资源法的基本制度之一,它作为一种基于市场的激励制度,可以实现环境资源的优化配置。但实践中排污权交易制度在我国目前尚处于探索阶段,对于一二级市场交易的几个重要问题,像污染物总量控制、污染权的确定、污染权的初始分配等都规定的过于概况,需要加以完善。 Emissions trading system is one of the basic systems of environmental resource law. It can realize the optimal allocation of environmental resources as a market-based incentive system. However, in practice, the trading system of emission rights is still in the exploratory stage in our country. There are several important issues concerning the primary and secondary market transactions, such as the total amount of pollutants, the determination of pollution rights, the initial distribution of pollution rights, etc. Need to be improved.